Our Commitment to the GDPR

The General Data Protection Regulation (GDPR) provides new, consistent standards across the EU to protect the rights of EU citizens regarding how their personal data is being used. It goes into effect on May 25, 2018 and applies to any company that uses personal data from EU citizens.

We are committed to privacy and security and will be ready for the GDPR before May 25, 2018. But that’s not all. As a Processor for your user data, we are also committed to making it easier for you to comply and equipping you, our customers, with easier paths towards your compliance with the GDPR.

Here we’ll provide a quick overview of GDPR and share what we’re doing to prepare.

GDPR Basics

Replacing the existing EU privacy directive 95/46/EC, which has been in place for over 20 years, the GDPR strengthens and expands the privacy rights of individuals in an era in which much of life takes place online.

The GDPR is extensive, affecting not just businesses based in the EU but also any company that processes the personal data of EU citizens. For instance, if you’re sending data about a person in the EU to Customer.io, it’s likely that the GDPR applies to you.

The Data Protection Principles set forth in the GDPR include requirements like the following:

Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.

Personal data should only be collected to fulfill a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.

Personal data should be held no longer than necessary to fulfill its purpose.

People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

We’d encourage you to read the text in full as well as to consult with your legal counsel for the most complete understanding of the GDPR.

What is Customer.io Doing to Prepare for GDPR?

As a customer who puts data about your end users into our product, you are a Data Controller. We act as a Data Processor for you. We’re also a Data Controller in supplying services to you (as a Customer.io customer) and making decisions about your personal data.

We’re getting ready for GDPR by preparing for our own compliance — as well as making it easy for you to comply as a data controller. Here is an overview of what we’ve been doing so far:

Data Processing Agreement

We’re reviewing all our legal agreements and making any required changes to be GDPR compliant. We are updating our Data Processing Agreement, Terms of Service, and Privacy Policy and will post them on our website in advance of the GDPR deadline. We are also making sure that any vendors we use as sub-processors are GDPR compliant.

Security and Data Management

Customer.io already employs strict policies and procedures around security and data management. Additionally, we have designated an internal team and engaged outside expertise to enhance security standards that protect our customer’s data and follow GDPR requirements.

We are appointing a Data Protection Officer to ensure ongoing GDPR compliance.

We are putting processes in place so that in the unlikely event of a data breach we ensure prompt notifications to customers and GDPR authorities as required.

We are formalizing and documenting our internal policies related to data security.

We are putting safeguards in place to ensure secure and proper handling of data stored outside of the EU as required.

We will continue, as has been our practice, to only process personal data according to our customer’s instructions.

Expanding Product Capabilities

To help you comply with article 24 (responsibility of the controller) and your end users’ requests related to the right to access, data portability, right to erasure, right to object and the right to restrict processing — we're enhancing Customer.io with new product capabilities which will be available in early 2018.

Easy profile export: You’ll be able to export all data about a single profile in a simple standardized format to help you with requests from your end users regarding right to access and data portability.

Automatic suppression: We're adding a new API endpoint that allows us to block any associated incoming personal data to help you comply with requests regarding the right to object or restrict.

Audit trail: Customer.io has provided limited auditing information upon request to date. We're expanding and enhancing this capability by adding full audit trails for all changes to your Customer.io account.

Existing Product Capabilities

Customer.io already enables compliance with requirements regarding the right of data rectification and the right to be forgotten:

Right to rectify user data: GDPR gives individuals the right to rectify any inaccurate or incomplete personal data. In Customer.io, data can be adjusted at any time with a simple identify call. This will create or update the associated profile with the newly provided data.

Right to be forgotten: We make it easy for you to honor delete requests from your end users by calling the DELETE API, or using the UI to delete a profile. We ensure that any associated user data and historical data are quickly and permanently deleted from our data stores.

Accountability: Customer.io has role-based permissions, supports encryption at rest of all associated account data, and many data management tools.

We fully support the GDPR and think it’s a good thing to treat customers and their data with care and respect. Our mission is to help companies like yours create better customer experiences with relevant communication and that requires the fair and secure use of personal data that was given with full consent and transparency.

If you have any questions or concerns regarding GDPR and Customer.io, please send us a detailed message to gdpr@customer.io.